Jones v. JP Morgan Chase & Co.

CourtCourt of Appeals for the Second Circuit
DecidedSeptember 19, 2025
Docket25-86
StatusUnpublished

This text of Jones v. JP Morgan Chase & Co. (Jones v. JP Morgan Chase & Co.) is published on Counsel Stack Legal Research, covering Court of Appeals for the Second Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Jones v. JP Morgan Chase & Co., (2d Cir. 2025).

Opinion

25-86 Jones v. JP Morgan Chase & Co.

UNITED STATES COURT OF APPEALS FOR THE SECOND CIRCUIT

SUMMARY ORDER RULINGS BY SUMMARY ORDER DO NOT HAVE PRECEDENTIAL EFFECT. CITATION TO A SUMMARY ORDER FILED ON OR AFTER JANUARY 1, 2007, IS PERMITTED AND IS GOVERNED BY FEDERAL RULE OF APPELLATE PROCEDURE 32.1 AND THIS COURT’S LOCAL RULE 32.1.1. WHEN CITING A SUMMARY ORDER IN A DOCUMENT FILED WITH THIS COURT, A PARTY MUST CITE EITHER THE FEDERAL APPENDIX OR AN ELECTRONIC DATABASE (WITH THE NOTATION “SUMMARY ORDER”). A PARTY CITING A SUMMARY ORDER MUST SERVE A COPY OF IT ON ANY PARTY NOT REPRESENTED BY COUNSEL.

At a stated term of the United States Court of Appeals for the Second Circuit, held at the Thurgood Marshall United States Courthouse, 40 Foley Square, in the City of New York, on the 19th day of September , two thousand twenty-five.

Present:

DENNY CHIN, WILLIAM J. NARDINI, MARIA ARAÚJO KAHN, Circuit Judges. ____________________________________

SHARIFF AHMAD JONES,

Plaintiff-Appellant,

v. 25-86-cv

JP MORGAN CHASE & CO., JP MORGAN CHASE BANK N.A., SUSAN BUZZARD,

Defendants-Appellees. ∗ _____________________________________

For Plaintiff-Appellant: Peter C. Lomtevas, Schenectady, NY.

For Defendants-Appellees: Stephanie Schuster, Morgan, Lewis & Bockius LLP, Washington, DC (Melissa C. Rodriguez, Hanna

∗ The Clerk of Court is respectfully directed to amend the caption as reflected above. 1 Martin, Morgan, Lewis & Bockius LLP, New York, NY, on the brief).

Appeal from a judgment of the United States District Court for the Northern District of

New York (Frederick J. Scullin, Jr., District Judge).

UPON DUE CONSIDERATION, IT IS HEREBY ORDERED, ADJUDGED, AND

DECREED that the judgment of the district court is AFFIRMED.

Plaintiff-Appellant Shariff Ahmad Jones appeals from a judgment entered on

December 30, 2024, by the United States District Court for the Northern District of New York

(Frederick J. Scullin, Jr., District Judge) dismissing his complaint as time-barred under Federal

Rule of Civil Procedure (“Rule”) 12(b)(6). Jones brought this action in New York State Supreme

Court, Onondaga County, on July 4, 2023, asserting one count of race discrimination in contracting

against Defendants-Appellees JP Morgan Chase & Co., JP Morgan Chase Bank N.A. (together,

“Chase Bank”), and Susan Buzzard (collectively, the “Defendants”), pursuant to 42 U.S.C. § 1981.

Jones’s complaint stems from a July 2013 incident in which Buzzard—then a Chase Bank

employee in Syracuse, New York—reported Jones to the police for purportedly attempting to

deposit a fraudulent traveler’s check. Buzzard’s report and subsequent testimony led to Jones

being convicted in state court for possession of a forged instrument and attempted petty larceny,

for which he served more than five years in prison before those convictions were overturned on

appeal based on the determination that the trial court had erroneously admitted hearsay evidence.

See People v. Jones, 158 A.D.3d 1103, 1104, 70 N.Y.S.3d 669, 670 (4th Dep’t 2018). After his

conviction was overturned, Jones was retried and acquitted of the charges on July 24, 2019.

On October 7, 2019, Jones filed a civil action for wrongful conviction and false

imprisonment against the State of New York. On May 4, 2023, that matter settled before the

2 commencement of trial. After the settlement and nearly four years after his acquittal, Jones

brought this personal injury action. Defendants timely removed the action to federal court and

then successfully moved to dismiss Jones’s complaint as time-barred by New York’s three-year

statute of limitations for personal injury claims. On appeal, Jones challenges the district court’s

ruling that his § 1981 claim is time-barred. We assume the parties’ familiarity with the case.

“We review de novo a district court’s grant of a motion to dismiss [under Rule 12(b)(6)],

including legal conclusions concerning the court’s interpretation and application of a statute of

limitations.” Castagna v. Luceno, 744 F.3d 254, 256 (2d Cir. 2014). 1 Generally, “[t]he lapse of

a limitations period is an affirmative defense that a defendant must plead and prove,” but “a

defendant may raise an affirmative defense in a pre-answer Rule 12(b)(6) motion if the defense

appears on the face of the complaint.” Staehr v. Hartford Fin. Servs. Grp., Inc., 547 F.3d 406,

425 (2d Cir. 2008).

The first question we must address is which statute of limitations period applies to Jones’s

§ 1981 claim. The Civil Rights Act of 1991 “enlarged the category of conduct that is subject to

§ 1981 liability,” Rivers v. Roadway Express, Inc., 511 U.S. 298, 303 (1994), and claims arising

under the expanded version of that statute are uniformly governed by a federal four-year statute of

limitations, Jones v. R.R. Donnelley & Sons Co., 541 U.S. 369, 382 (2004) (citing 28 U.S.C.

§ 1658). By contrast, all other § 1981 claims, which arise under the pre-amendment version of

the statute, are subject to the state-law limitations period that governs the most analogous state

cause of action. Id. at 377–78. In New York, that is the three-year limitations period that applies

to personal-injury claims set forth in N.Y. C.P.L.R. § 214(5). See Curto v. Edmundson, 392 F.3d

1 Unless otherwise indicated, when quoting cases, all internal quotation marks, alteration marks, emphases, footnotes, and citations are omitted. 3 502, 504 (2d Cir. 2004). So, we must determine whether Jones’s claim would have been

cognizable under the pre-amended version of § 1981, or whether it was made possible only by the

1991 amendment.

We conclude that Jones’s claim would have been cognizable under the pre-amended

version of § 1981, and so his claim is subject to New York’s three-year statute of limitations. In

Patterson v. McLean Credit Union, the Supreme Court recognized that the pre-amended version

of § 1981 “prohibits, when based on race, the refusal to enter into a contract with someone, as well

as the offer to make a contract only on discriminatory terms.” 491 U.S. 164, 176–77 (1989). The

holding in Patterson—that § 1981 “does not apply to conduct which occurs after the formation of

a contract and which does not interfere with the right to enforce established contract obligations,”

id. at 171—is what Congress addressed in its 1991 amendment by “adding § 1981(b), which

defines ‘make and enforce’ to bring postformation conduct . . . within the scope of § 1981,”

Domino’s Pizza, Inc. v. McDonald, 546 U.S. 470, 477 (2006). Jones’s complaint expressly

disavowed the existence of a contractual relationship with Chase Bank. See Appellant’s App’x

at 10 ¶ 22 (alleging that he “was not a Chase Bank account holder”); see id. at 10 ¶ 23 (“Mr. Jones

may have opened a Chase account had the cheque been genuine.”).

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Related

Patterson v. McLean Credit Union
491 U.S. 164 (Supreme Court, 1989)
Rivers v. Roadway Express, Inc.
511 U.S. 298 (Supreme Court, 1994)
Jones v. R. R. Donnelley & Sons Co.
541 U.S. 369 (Supreme Court, 2004)
Domino's Pizza, Inc. v. McDonald
546 U.S. 470 (Supreme Court, 2006)
Littlefield v. Acadia Insurance
392 F.3d 1 (First Circuit, 2004)
Kronisch v. United States
150 F.3d 112 (Second Circuit, 1998)
Pearl v. The City Of Long Beach
296 F.3d 76 (Second Circuit, 2002)
Bogle-Assegai v. Connecticut
470 F.3d 498 (Second Circuit, 2006)
Staehr v. Hartford Financial Services Group, Inc.
547 F.3d 406 (Second Circuit, 2008)
Castagna v. Luceno
744 F.3d 254 (Second Circuit, 2014)

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